Managing Patient Care via Telehealth (OME)

When a home care patient/family member or staff at a nursing or assisted living facility refuse health care provider visits, can telehealth be used for such visits ?

Any examples are for illustrative purposes only.

Yes.  While some aspects of care can be done via telehealth, not everything can be accomplished by telehealth when skilled care is required. The Home Health Agency (HHA) needs to work closely with the patient/family or facility to reassure them that visits from patient care providers are safe.  

If the patient continues to refuse any in-person visits as per the plan of care, (including assessment or other patient care visits)  the HHA will have to determine if the HHA can meet the patient’s medical, nursing, rehabilitative, and social needs in his or her place of residence.  The following documents, available on the CMS website, may assist families and caregivers in the screening of health care providers and their use of PPE:
 
Managing Visits via  Telehealth
Telehealth visits are not simply a phone conversation. Such visits may include the use of secure telecommunications technology.

Audio-Only Telehealth for Certain Services (update from CMS 04/29/20):
CMS is waiving the requirements for interactive (two-way, real-time) telecommunications systems to furnish telehealth services, to the extent they require use of video technology, for certain services. This waiver allows the use of audio-only equipment to furnish services described by the codes for audio-only telephone evaluation and management services, and behavioral health counseling and educational services (https://www.cms.gov/Medicare/Medicare-General-Information/Telehealth/Telehealth-Codes). Unless provided otherwise, other services included on the Medicare telehealth services list must be furnished using, at a minimum, audio and video equipment permitting two-way, real-time interactive communication between the patient and distant site physician or practitioner. 

Hospice providers, per the CMS Interim Final Rule issued 3/30/200, can provide services to a Medicare patient receiving routine home care through telehealth, if it is feasible and appropriate to do so.  Patient recertification for the Medicare hospice benefit can also now be conducted via telehealth. 

Home Health Agencies (HHAs) can provide more services to beneficiaries using telehealth within the 30-day episode of care, so long as it’s part of the patient’s plan of care and does not replace needed in-person visits as ordered on the plan of care.
 
Medicare required initial assessments to determine the immediate care and support needs of the patient and determine eligibility for the Medicare home health benefit, including homebound status, can be performed remotely or by record review.

Scope and frequency of documentation on the plan of care for telehealth visits
Per CMS, Home Health Agencies (HHAs) can provide telehealth services but, they need to be part of the patient’s plan of care (POC) and do not replace needed in-person visits.  There may need to be changes to the existing or new plans of care for frequency and type of in-person visits as a result of using telehealth visits.

For organizations that use Joint Commission accreditation for deemed status purposes, please monitor the CMS website as waivers are being approved frequently and may include state-specific waivers. Click here to access the CMS website: 

Additional Resources:
Coronavirus (COVID-19) Guidance and Resources
Last updated on September 10, 2020
Manual: Home Care
Chapter: Provision of Care Treatment and Services PC

If no, please comment on how we could improve this response.

If you have additional standards-related questions regarding this topic, please use the Standards Online Submission Form